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The applicant asks whether transferring a property to a new company through a partial demerger allows for the application of the special Corporate Tax regime. The DGT rules that, as it is an isolated property without a distinct business organisation, it does not constitute a business line.
This ruling limits the use of special tax regimes for demergers involving single assets, as they must represent a functional business unit rather than just an isolated piece of property.
The tax team reviews your specific situation.
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